Comment: Sibanye Gold Tailing Re-treatment Project

The Federation for a Sustainable Environment's (FSE) position on the re-mining and consolidation of poorly managed, poorly constructed and poorly monitored historical tailings storage facilities, which are significant sources of water and windblown dust pollution, has been published in a number of academic papers, government reports and comments and response reports.

While the FSE is in support of the re-mining of historical tailings storage facilities and the reclamation of Au, U and sulphur and the consolidation of mine residue in a regional tailings storage facility, the FSE wishes to raise the following issues of concern and call upon the Applicant to address these [an extract from the document which is available to download in full]:

In the past dump reclamation activities, a number of cases have been identified where the re-mining of dumps was not completed, either due to a lack of funding on the part of the miner or due to the heterogeneity in the dumps which were mined. Any new application to exploit mine residues should only be approved if it involves the removal of an entire residue deposit and the rehabilitation of the remaining footprint. If this is not the case, rather than consolidating contaminated sites, the reprocessing activities result in the creation of two contaminated sites, where one previously existed.

The past practice of granting rights and authorization for the reprocessing of individual residue deposits may need to be reviewed insofar as it allows the selective extraction of value from portions of a site without ploughing some of that value back into the rehabilitation of the entire mining area. It must be accepted that the reprocessing of some mining residues will never be economically viable and that these will need to be transported to the regional tailings storage facility.

Radiometric surveys over previously reprocessed mine residue deposit footprints have, in some cases, shown elevated levels of residual radioactivity in soils. In these cases, it must be accepted that some areas will never be suitable for unrestricted development and that these areas will need to be demarcated as such, and appropriated land-uses proposed and implemented.

The latent impacts on biota, including humans, of bioaccumulation and exposure to elevated levels of metals and NORMs are established in the international scientific literature. The mining industry should have gained enough experience from the asbestosis and silicosis catastrophes in South Africa to justify application of precautionary principles in respect of other suspected latent impacts. We recommend that gold mining operations in South Africa adopt the precautionary approach, and consider the following risks when determining re-mining, rehabilitation, closure and financial provisions for rehabilitation and closure:

The near certainty of contaminated water, which will require some form of decontamination treatment, decanting from closed underground mines, or from lower-lying interconnected neighbouring mines;

The near certainty of sulphate, chloride, metal and NORM contamination of soils and sediments by seepage from unlined tailings storage facilities (TSFs), tailings spillages and plant discharges and the potential for contamination of downstream /downwind soils and sediments;

The near certainty of sulphate, chloride, metal and NORM contamination of surface water bodies and their sediments, and ground water, by seepage from unlined tailings storage facilities, tailings spillages, plant discharges and underground workings. In addition, the potential contamination of surface soils overlying shallow polluted groundwater via evaporative pathways during dry seasons.

Research News

This booklet makes the case for a project to address the waste and pollution legacy of mining in the Witwatersrand basin, with a clear linkage between the potential for revenue generation through materials reclamation and comprehensively addressing the entire rehabilitation challenge, with the participation of all stakeholders. It sketches the background and the extent of the challenge, the legislative and regulatory context and the imperatives for urgent action, then focuses in on the Tweelopiespruit wetlands area for a potential pilot project.

Over the past years we have had the pleasure of watching a greater measure transparency, honesty and openness in the mining industry and the publishing of Regulations calling for easier access by the public to Environmental Management Programme Reports, Audit Reports, Water Use Licenses, closure plans and financial provisions.

"The 2006 Energy Review merely exacerbated the problem. It acknowledged that the UK would not meet its emissions targets without nuclear, but did almost nothing to address the problem of the reluctance of the market to fund a new generation of plants.

Uranium has been considered both a radiological and also a heavy metal poison, following calcium in its distribution within the body, i.e. building up in bone, and with the principle target for toxicity being the lung and the kidney. Recently, it has been shown that uranium also targets the brain.

The Federation for a Sustainable Environment's (FSE) position on the re-mining and consolidation of poorly managed, poorly constructed and poorly monitored historical tailings storage facilities, which are significant sources of water and windblown dust pollution, has been published in a number of academic papers, government reports and comments and response reports.

"It is not uncommon for African governments to exploit the poor and marginalized for perceived gains in the interest of the strong multinational companies and a few local beneficiaries."Endowed with vast natural resources such as wild animals, unique flora and fauna, rivers, lakes and minerals such as copper, uranium, zinc, diamonds and silver to mention but a few, many governments in Africa, rather than improving the lives of their citizens end up piling misery on the vulnerable in society."Take the mining of uranium for instance. It holds so much promise on the face of it but deep down the layers of reality, one sees that only multinational companies, corrupt government officials among them, only a token few locals benefit from its exploitation."
Download the report.

A critical evaluation of the challenges facing dust management within gold mining regions of South Africa by JJ Martins
Extract:
"...the biggest challenge within this area is that neither districts nor gold mines receive any assistance nor do they report to government with regards to their dust management programme. This poses a challenge as it limits both the districtâ€Ÿs and gold mines â€Ÿability to enforce and improve their dust management programmes. The lack of use of information provided by interested and affected parties (Paragraph 4.3.8) within the dust management plan of both the district and gold mines is a major challenge as deposition-dust regulations were initiated to protect the public and their property ... in the first place. The biggest challenge, however, as identified in the study for this focus area is the lack of specialist involvement in dust management plans and programmes of both districts and gold mines ... There are, however, implications regarding the capacity of consultants rendering services as air-quality specialists ....). It is the view of the author that when it comes to using consultants a clear distinction should be made between dust management and monitoring as the necessary qualifications relevant to each of the areas are totally different. It was confirmed by questionnaires to specialists ... that there is a general lack of scientific knowledge within dust management. It is furthermore the author's view that to render air-quality services specifically pertaining to monitoring one should at least have a tertiary qualification in science."

The hazardous mining by-product raises two questions – who’s to blame and who should pay.
The acid mine drainage crisis is going to cost someone a lot of money, but probably not the people who caused it. The “polluter pays” principle was next to impossible to apply to the acid mine drainage problem in a retrospective way, said Marius Keet, chief director for mine water management at the department of water and sanitation.

The Federation for a Sustainable Environment is proud to announce the launch of the booklet titled “Rehabilitation of Mine Contaminated Eco-Systems. A Contribution to a Just Transition to a Low Carbon Economy to Combat Unemployment and Climate Change” by Mariette Liefferink of the Federation for a Sustainable Environment (FSE). The booklet was commissioned by the Alternative Information and Development Centre (AIDC) in collaboration with the Friedrick Ebert Stiftung.

Last week, the coalition of eight civil society and community organisations that has been resisting the proposed coal mine inside a protected area and strategic water source area in Mpumalanga launched further proceedings in the Pretoria High Court.

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